FERMA’s position on the Revision of the Cybersecurity Act

Published on 20 June 2025

FERMA has submitted a response to the European Commission’s consultation on the revision of the Cybersecurity Act, calling for the simplification of cyber reporting requirements.

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The revision of the Cybersecurity Act is critical to the risk management community for two reasons:

On the one hand, it aims to enhance the overall cybersecurity maturity of the EU as cyber threats are becoming ever more prevalent; according to FERMA Global Risk Manager Survey Report 2024, cyberattacks identified as the most important risk by Risk Managers worldwide.

On the other hand, it seeks to reduce the reporting burden caused by the overlap of multiple EU cyber legislation (GDPR, NIS2, DORA, Cyber Resilience Act etc.) — a concern that FERMA raised in our 2024 Cyber Reporting Stack: Navigating EU requirement white paper.

In our contribution, we advocate for the establishment of a ‘single-point-of-entry system’ for cyber incidents reporting. We also call for the harmonisation of timelines and definitions to ensure the consistent interpretation of EU legislation and reporting standards across member states.

Moreover, FERMA believes that ENISA has an important role to play in enhancing the cyber resilience of the EU economy. We call for ENISA to support industry stakeholder in the form of best practices and guidance to address both technical and non-technical cyber risks, in line with a multi-risk approach compatible with an Enterprise-wide Risk Management (ERM) methodology.

Lastly, we call for cyber risk management processes to be the topic of a dedicated European cybersecurity certification. This would be a clear indicator for relevant stakeholders, such as business partners or insurance providers, that the certified organisation has robust cyber risk management practices in place, which will contribute to fostering trust in the market.

FERMA maintains a watchful eye on next steps and will work with its network to ensure that EU cyber legislation is fit for purpose and straightforward, and contributes to effective cyber risk management practices across the EU.

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